You are a new associate for Bull & Bear, LLP, a CPA firm located in the greater Hartford area. Your manager has come to you with a question presented by one of the firm’s clients: Blackacre Enterprises Corporation needs to upgrade to a larger manufacturing facility. Blackacre Enterprises plans to first acquire a new manufacturing facility for $12,100,000 cash and then transfer the facility it was using (building and land) to Whiteacre Corporation for $12,000,000 three months later. Issue: Will the exchange qualify for like-kind exchange treatment? If not, how can Blackacre change the transaction so that it will qualify?

Prepare a tax memorandum, no longer than 4 single spaced pages in length, using the tax memorandum structure described in the materials.

Be sure to attach your authorities (the documents you researched in order to solve this question).

hints: Revenue Procedure 2000-37 Revenue Procedure 2004-51